There is evidence that the company has a publicly stated anti-corruption commitment, which details the company\u2019s stance against corruption within the organisation. It is clear that this commitment was authorised and endorsed by the company\u2019s leadership. <\/p>\n"},{"question":55,"commitment_area":7,"score":"1","comments":"
There is evidence that the company publishes various anti-corruption policies: a Vigilance Manual; Principles and Policies of Business Responsibility; and a Code of Business Conduct and Ethics for Board Members and Senior Management. The Vigilance Manual specifies prohibition of bribery and payments to public officials and applies to all employees. The Principles and Policies of Business Responsibility specifies commercial bribery with regards to employees. The Code of Business Conduct and Ethics for Board Members and Senior Management, in which reference is made to corruption and ethics, applies to all board members, including non-executive directors. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that any of the policies or codes specifically address or prohibit facilitation payments. <\/p>\n"},{"question":56,"commitment_area":7,"score":"1","comments":"
There is evidence that a designated board committee \u2013 the Corporate Level Vigilance Committee \u2013 is ultimately responsible for oversight of the company\u2019s anti-bribery and corruption programme. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that this committee engages in formal oversight functions, such as reviewing reports from management or the results of internal and external audits. <\/p>\n"},{"question":57,"commitment_area":7,"score":"1","comments":"
Based on publicly available information, there is evidence that a managerial-level individual \u2013 the Chief Vigilance Officer \u2013 has been assigned ultimate responsibility for implementing and managing the company\u2019s anti-bribery and corruption programme. The Chief Vigilance Officer also serves as the Committee Secretary to the Corporate Level Vigilance Committee which provides oversight of the anti-bribery and corruption programme. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is evidence to indicate that this individual is a senior executive.<\/p>\n"},{"question":58,"commitment_area":8,"score":"2","comments":"
Based on publicly available information, there is evidence that the company has a formal bribery and corruption risk assessment procedure that informs the design of the anti-bribery and corruption programme. The company indicates that results of risk assessments are reviewed by the board on at least an annual basis. There is also evidence that the results of these reviews are used to develop tailored mitigation plans and to update specific parts of the company\u2019s anti-bribery and corruption programme. <\/p>\n"},{"question":59,"commitment_area":8,"score":"0","comments":"
There is no evidence that the company\u2019s anti-bribery and corruption programme is subject to audit or review. The company indicates that some of its policies \u2013 including those covering anti-bribery and corruption controls \u2013 are reviewed periodically; however the frequency of these reviews is unclear and there is no evidence that the company\u2019s programme as a whole is reviewed regularly. There is also no evidence that high-level findings are presented to the board or that a designated team or individual has responsibility for updating the policies. <\/p>\n"},{"question":60,"commitment_area":8,"score":"2","comments":"
There is evidence that the company publicly commits to investigating incidents promptly, independently and objectively and that the company takes steps to ensure the independence of its investigations. There is evidence that the company commits to reporting major investigative findings to senior management and the board. For whistleblowing cases, there is evidence of a procedure in place that stipulates documentation and actions to be taken at every step of the case, from the receipt to final outcome. The company also commits to inform whistleblowers of the outcome, if they so wish. There is also evidence to indicate that a senior central body receives and reviews summary of all incidents and their status in the organisation on an annual basis. <\/p>\n"},{"question":61,"commitment_area":8,"score":"1","comments":"
There is evidence that the company assures itself of the quality of its internal investigations regarding both incident investigations and whistleblowing cases. There is also evidence that the company reviews its whistleblowing mechanism on an annual basis. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that staff responsible for conducting investigations are properly trained or qualified. In addition, the company does not provide any information to indicate how complaints about the investigation are handled or who is responsible for handling such complaints. <\/p>\n"},{"question":62,"commitment_area":8,"score":"2","comments":"
There is evidence that the company makes a clear commitment to report material findings of corruption from investigations to the board. The company states that the \u2018Competent Authority\u2019 (the Chairman and Managing Director) is ultimately responsible for ensuring that the disclosure of criminal offences to relevant authorities is evaluated and acted upon if found necessary.<\/p>\n"},{"question":63,"commitment_area":8,"score":"0","comments":"
There is some evidence that the company publishes information about complaints in relation to vigilance matters. However, the company receives a score of \u20180\u2019 because there is no evidence that the company publishes any data on ethical or bribery and corruption investigations or disciplinary actions involving its employees. <\/p>\n"},{"question":64,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company provides vigilance training for all employees. However, the company receives a score of \u20181\u2019 because there is no clear evidence that this training covers anti-bribery and corruption, and the company also does not provide further information on how frequently employees are required to undertake this training. <\/p>\n"},{"question":65,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is some evidence that employees in certain positions receive different or tailored anti-bribery and corruption training. However, the company receives a score of \u20181\u2019 because it does not make specific reference to all three categories of employee referred to in the question. There is also no evidence that training for employees in high risk positions is refreshed on at least an annual basis.<\/p>\n"},{"question":66,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company measures or reviews the efficacy of its anti-corruption communications or training programme. <\/p>\n"},{"question":67,"commitment_area":9,"score":"0","comments":"
There is no publicly available evidence that the company\u2019s incentive schemes incorporate ethical or anti-bribery and corruption principles. <\/p>\n"},{"question":68,"commitment_area":9,"score":"0","comments":"
There is no evidence that the company commits to protect and support any employee who refuses to act unethically, including in cases where such actions may result in a loss of business or another disadvantage to the company. There is some evidence that the company accepts business loss arisen as a consequence of a bona-fide commercial\/operational decision, however this doesn\u2019t specifically relate to anti-bribery and corruption or supporting employees to do the right thing. <\/p>\n"},{"question":69,"commitment_area":9,"score":"1","comments":"
There is evidence that the company promotes a clear policy of non-retaliation against both whistleblowers and employees who report bribery and corruption incidents which explicitly applies to all employees across the organisation, including those employed by the group as third parties and suppliers. This is understood to also apply to employees of joint ventures, although they are not specifically mentioned in the list of stakeholders. <\/p>\n
The company receives a score of \u20181\u2019 because there is no evidence that the company assures itself of its employees\u2019 confidence in this commitment through surveys, usage data or other clearly stated means. <\/p>\n"},{"question":70,"commitment_area":9,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has some whistleblowing and advice channels which are confidential. The company states that these channels are available to all employees in any country of operation and to any employees of third parties, suppliers and joint venture partners.<\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence that it offers externally operated reporting channels and there is no clear evidence that the channels are available in multiple relevant languages. <\/p>\n"},{"question":71,"commitment_area":10,"score":"1","comments":"
There is publicly available evidence that the company has policies covering conflicts of interest, which include actual and potential conflicts and apply to all employees and board members. There is evidence that the policies cover possible conflicts relating to employee relationships, financial interests and other employment. However, the company receives a score of \u20181\u2019 because there is no evidence that its policies address government relationships. <\/p>\n"},{"question":72,"commitment_area":10,"score":"0","comments":"
There is some evidence that the company has procedures to manage conflicts of interest, including disciplinary actions for breaches of the policy. However, these procedures are sufficiently unclear that they do not satisfy the requirements of score \u20181\u2019.<\/p>\n"},{"question":73,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company has a policy regulating the employment of current or former public officials. <\/p>\n"},{"question":74,"commitment_area":10,"score":"0","comments":"
There is no evidence that the company reports details of the contracted services of serving politicians. <\/p>\n"},{"question":75,"commitment_area":11,"score":"2","comments":"
The company publishes a clear statement that it does not make any political contributions under any circumstances to any party, candidate or campaign. <\/p>\n"},{"question":76,"commitment_area":11,"score":"N\/A","comments":"
The company publishes a clear statement that it does not make any political contributions, and is therefore exempt from scoring on this question. <\/p>\n"},{"question":77,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company has a policy or procedure covering charitable donations and sponsorships. There is some publicly available evidence that the company undertakes CSR activities and aims to ensure that they are conducted in an ethical manner, however this information is insufficiently detailed to receive a score of \u20181\u2019. <\/p>\n"},{"question":78,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company has a policy or procedure on lobbying. <\/p>\n"},{"question":79,"commitment_area":11,"score":"0","comments":"
There is no publicly available evidence that the company publishes any information on its lobbying aims, topics or activities. <\/p>\n"},{"question":80,"commitment_area":11,"score":"0","comments":"
There is no evidence that the company publishes any details about its global lobbying expenditure.<\/p>\n"},{"question":81,"commitment_area":11,"score":"1","comments":"
Based on publicly available information, there is evidence that the company has a policy on the giving and receipt of gifts. The company\u2019s Code of Business Conduct and Ethics for Board Members and Senior Management specifies a financial limit for gifts for special events. <\/p>\n
However, the company receives a score of \u20181\u2019 because its policy does not address the risks associated with gifts and hospitality given to\/received from domestic or foreign public officials. In addition, there is no evidence that all gifts and hospitality above a certain threshold are recorded in a dedicated central register that is accessible to those responsible for oversight of the process.<\/p>\n"},{"question":82,"commitment_area":12,"score":"1","comments":"
Based on publicly available information, there is evidence that the company\u2019s procurement department is involved, in some capacity, in the establishment of supplier relationships. <\/p>\n
However, the company receives a score of \u20181\u2019 because it is not clear that the procurement department is the main body responsible for oversight of the company\u2019s supplier base; for instance there is also evidence to show that the company\u2019s Vigilance Department provides some oversight over these processes. Furthermore, there is no evidence that the company assures itself of the procurement department\u2019s involvement at least every three years. While evidence of the use of Integrity Pacts for large value contracts has been noted, these are not explicitly related to the question. <\/p>\n"},{"question":83,"commitment_area":12,"score":"1","comments":"
There is evidence that the company has formal procedures to conduct due diligence on its suppliers and that suppliers are reviewed annually. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no evidence to suggest that highest risk suppliers are subject to enhanced due diligence. Furthermore, it is not clear whether the company might be willing to review and terminate supplier relationships in circumstances where a red flag highlighted cannot be mitigated. <\/p>\n"},{"question":84,"commitment_area":12,"score":"1","comments":"
There is some evidence that the company ensures that its suppliers have adequate anti-bribery and corruption policies and procedure in place. There is evidence that the company ensures this in practice by stipulating certain contractual terms and by advising suppliers to have a Company Code of Conduct. This assurance is conducted when onboarding new suppliers. <\/p>\n
However, the company receives a score of \u20181\u2019 because there is no clear evidence that all suppliers must have, at least, policies that prohibit facilitation payments, policies that cover conflicts of interest, gift and hospitality and whistleblowing. Furthermore, it is not clear that the company assures itself of this for all suppliers. <\/p>\n"},{"question":85,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company takes steps to ensure that the substance of its anti-bribery and corruption standards are required throughout the supply chain. Although there is evidence that the company takes steps to ensure the compliance of its suppliers, it is not clear that it applies to sub-contractors and other related entities. <\/p>\n"},{"question":86,"commitment_area":12,"score":"0","comments":"
There is no evidence that the company publishes data on ethical or corruption-related investigations or associated disciplinary actions involving its suppliers. The company publishes some details on its complaints and investigations related to vigilance, however this is not sufficiently clear to merit a score of \u20181\u2019. <\/p>\n"},{"question":87,"commitment_area":13,"score":"0","comments":"
Based on publicly available information, there is some evidence that the company acknowledges the corruption risks associated with the use of agents, by stating that such entities should not seek or accept bribes. <\/p>\n
However, the company receives a score of \u20180\u2019 because it does not publish further details of controls to mitigate the specific risks associated with agents. Furthermore, the company does not explicitly commit to establishing and verifying that the use of agents is, in each case, necessary to perform a legitimate business function. <\/p>\n"},{"question":89,"commitment_area":13,"score":"0","comments":"
There is no clear evidence that the company has formal procedures in place to conduct anti-bribery and corruption due diligence prior to engaging and when working with agents and intermediaries. There is some indication that the company has formal procedures to conduct due diligence prior to engaging with consultants and vendors, but it is not clear that this includes agents, nor whether it covers anti-bribery and corruption considerations. <\/p>\n"},{"question":90,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company aims to establish the beneficial ownership of its agents. <\/p>\n"},{"question":91,"commitment_area":13,"score":"0","comments":"
There is some evidence that the company\u2019s prohibition of bribery applies to agents. However, the company receives a score of \u20180\u2019 because there is no indication that the company includes anti-bribery and corruption clauses in its contracts with agents and intermediaries. <\/p>\n"},{"question":92,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company mentions incentive structures as a risk factor in agent behaviour.<\/p>\n"},{"question":98,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company publishes any details of the agents currently contracted to act for or on behalf of the company. <\/p>\n"},{"question":99,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company publishes any data on ethical or bribery and corruption related investigations, incidents or associated disciplinary actions involving agents. <\/p>\n"},{"question":100,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company conducts anti-bribery and corruption due diligence on its joint ventures. <\/p>\n"},{"question":101,"commitment_area":13,"score":"0","comments":"
There is some evidence that the company acknowledges where it could incur liability for corruption when entering into joint venture partnerships. However, there is no evidence that the company commits to establishing or implementing anti-bribery and corruption policies or procedures in its joint ventures. In addition, there is no evidence that it requires anti-bribery and corruption clauses in its contracts with joint venture partners.<\/p>\n"},{"question":102,"commitment_area":13,"score":"0","comments":"
There is no publicly available evidence that the company commits to take an active role in preventing bribery and corruption in all of its joint ventures. <\/p>\n"},{"question":103,"commitment_area":14,"score":"0","comments":"
There is no publicly available evidence that the company addresses the corruption risks associated with offset contracting. <\/p>\n"},{"question":104,"commitment_area":14,"score":"0","comments":"
There is no publicly available evidence that the company has formal procedures in place to conduct risk-based anti-bribery and corruption due diligence on its offset obligations. <\/p>\n"},{"question":105,"commitment_area":14,"score":"0","comments":"
There is no publicly available evidence that the company publishes any details of the offset agents, brokers or consultancy firms currently contracted to act with and on behalf of its offset programme. <\/p>\n"},{"question":106,"commitment_area":14,"score":"0","comments":"
There is evidence that the company publishes some information on its offset obligations. However, the information published is insufficiently detailed to satisfy the requirements of score \u20181\u2019.<\/p>\n"},{"question":107,"commitment_area":15,"score":"0","comments":"
There is some indication that the company acknowledges the risks associated with entering into new markets, however there is no evidence that the company acknowledges or manages the corruption risks associated with different markets, so the company receives a score of \u20180\u2019. <\/p>\n"},{"question":108,"commitment_area":15,"score":"2","comments":"
There is some evidence that the company publishes a list of its consolidated and non-fully consolidated holdings. This list is updated on an annual basis and is accompanied by the date and signatures of the company\u2019s leadership. The information includes the percentages owned, the country of incorporation and the country of operation for one entity. The company lists the \u201cplace of business\u201d for the other two entities, which is understood to represent the country of incorporation. <\/p>\n"},{"question":109,"commitment_area":15,"score":"1","comments":"
The company publishes information about the beneficial ownership of shareholders with at least 5% of shares up to March 2019. The company\u2019s publicly available information does not provide the names of the specific shareholding entities, and indicates that the Government of India holds between 58.83% and 68.19% of shares. <\/p>\n
Furthermore, the company does not disclose its ownership in a freely-accessible central public register. It is noted that the company publicly lists shares on the National Stock Exchange of India and the Bombay Stock Exchange, however these exchanges are not specified on the list of regulated markets outlined in the scoring criteria.<\/p>\n"},{"question":110,"commitment_area":15,"score":"0","comments":"
There is evidence that the company publishes some information about its customers. However, this information is not provided in a format from which the percentage breakdown of defence sales by customer can be deduced, so the company receives a score of \u20180\u2019.<\/p>\n"},{"question":111,"commitment_area":16,"score":"1","comments":"
The company publishes information about the beneficial ownership of shareholders with at least 5% of shares up to March 2018, and it appears that the share of voting rights that any given shareholder retains is equal to the number of shares owned. However, the information published for March 2019 only provides shareholder by category and does not refer to specific shareholders by name, so the company receives a score of \u20181\u2019.<\/p>\n"},{"question":112,"commitment_area":16,"score":"2","comments":"
Based on publicly available information, there is evidence that the company publishes information about its objectives on its website and in the Annual Report. The company states that its primary objectives are to generate growth, fuel technological development and support national defence exports. Although the company does not directly state that these objectives are updated and reviewed on an annual basis, the inclusion of this information in the company\u2019s Annual Report is sufficient to satisfy this criterion.<\/p>\n"},{"question":113,"commitment_area":16,"score":"1","comments":"
There is evidence that the company publishes clear information about the composition of its board and whether each board member is an executive, a state representative or an independent board member. There is information that the Government of India appoints the Directors and Independent Directors. <\/p>\n
However, the company receives a score of \u20181\u2019 because it does not provide further information about the nomination process for board members, such as which individuals are involved in the nomination and who makes the final appointment decision.<\/p>\n"},{"question":114,"commitment_area":16,"score":"2","comments":"
Based on publicly available information, there is clear evidence that the company\u2019s executive-level audit committee is composed of a majority of independent directors. The company discloses the name and status of each member. <\/p>\n"},{"question":115,"commitment_area":16,"score":"0","comments":"
Based on publicly available information, there is insufficient evidence to suggest that the company has a system in place to manage asset transactions. The company makes some reference to the role of the vigilance organisation in reviewing asset acquisitions and the role of directors in maintaining proper accounting records, but this information does not satisfy the requirements of score \u20181\u2019.<\/p>\n"}],"main_products_and_services":false},"_links":{"self":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies\/450","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/companies"}],"about":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/types\/companies"}],"wp:attachment":[{"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/media?parent=450"}],"wp:term":[{"taxonomy":"countries","embeddable":true,"href":"https:\/\/ti-defence.org\/dci\/wp-json\/wp\/v2\/countries?post=450"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}